Credit Bureau Connection, Inc. v. Pardini, et al.

Filing 91

STIPULATION AND ORDER FOR SUBMISSION OF CLOSING DOCUMENTS EXTENDED to 8/4/2011. Order signed by Magistrate Judge Dennis L. Beck on 7/12/2011. (Hernandez, M)

1
2
3
4
5
6
7
8
9

KRISTI W. DEAN, ESQ., S.B. #117358
[e-mail]
LESLIE A. BLOZAN, ESQ., S.B. #081481
[e-mail]
AMY W. LEWIS, ESQ., S.B. #158999
[e-mail]
STONE | ROSENBLATT | CHA
A Professional Law Corporation
21550 Oxnard Street, Main Plaza – Suite 200
Woodland Hills, California 91367
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiff and Cross-Defendant,
CREDIT BUREAU CONNECTION, INC., a California Corporation

10

STONE | ROSENBLATT | CHA

A PROFESSIONAL LAW CORPORATION
21550 OXNARD STREET, MAIN PLAZA – SUITE 200
WOODLAND HILLS, CALIFORNIA 91367

11

DAVID A. MAKMAN, ESQ., S.B. #178195
LAW OFFICES OF DAVID MAKMAN

12

90 NEW MONTGOMERY STREET, SUITE 600
SAN FRANCISCO, CA 94105
TEL: [phone]
FAX: [phone]

13
14
15

Attorneys for Defendants and Counter-Claimants,

16

WILLIAM PARDINI, and B.T.B., Inc.

17
18

UNITED STATES DISTRICT COURT

19

EASTERN DISTRICT OF CALIFORNIA

20
21

Case No.: CV-F-10-1202 LJO-DLB
[Complaint filed: 7/1/2010]
[Assigned for all Purposes to the
Honorable Lawrence J. O’Neill,
Ctrm. DJ]

CREDIT BUREAU CONNECTION,
INC., a California Corporation

22
Plaintiff(s),

23
24
25
26
27

v.

STIPULATION FOR SUBMISSION
OF CLOSING DOCUMENTS AND
PROPOSED ORDER

WILLIAM PARDINI, an individual;
B.T.B., INC., a California Corporation
dba DATA CONSULTANTS,

28

Defendants.
1
STIPULATION FOR SUBMISSION OF CLOSING DOCUMENTS AND [PROPOSED] ORDER
10cv1202.o.Stip Closing Doc

1
2

B.T.B., INC., a California Corporation,
dba DATA CONSULTANTS,
Counter-Claimant,

3
4
5
6

v.
CREDIT BUREAU CONNECTION,
INC., a California Corporation, and
DARIN LARSEN, an individual.
Counter-Defendants.

7

The parties respectfully submit this Stipulation and Proposed Order as

8
9

follows:
The parties to the above captioned lawsuit participated in multiple

10

STONE | ROSENBLATT | CHA

A PROFESSIONAL LAW CORPORATION
21550 OXNARD STREET, MAIN PLAZA – SUITE 200
WOODLAND HILLS, CALIFORNIA 91367

11

settlement conferences and settled their dispute on May 18, 2011. On that

12

date, the parties signed a six page Memorandum of Understanding which

13

memorializes the settlement terms. Since then, the parties have diligently

14

exchanged multiple drafts of the closing documents, including a draft

15

Settlement and Mutual Release Agreement, an eCredit Use Agreement, a

16

License and Support Services Agreement, and an Assignment of Copyright

17

Agreement. Due to the complexity of the documents and other

18

commitments, the documents have not yet been finalized.
Counsel will continue to work diligently to complete the closing

19
20

documents and expect that the documents will be signed on or before

21

August 1, 2011. Counsel will then execute a Stipulation for Dismissal on or

22

before August 4, 2011.
If it appears that the parties cannot agree on any provisions of the final

23
24

documents, plaintiff’s counsel will contact Magistrate Judge Dennis L. Beck

25

for a telephonic conference on or before August 4, 2011.

26

///

27

///

28

///
2
STIPULATION FOR SUBMISSION OF CLOSING DOCUMENTS AND [PROPOSED] ORDER
10cv1202.o.Stip Closing Doc

1

DATED: July 11, 2011

2

STONE | ROSENBLATT | CHA
A Professional Law Corporation

3
4

By:

5
6
7
8
9
10

/s/
Kristi W. Dean, Esq.
Leslie A. Blozan, Esq.
Amy W. Lewis, Esq.
Attorneys for Plaintiff/CrossDefendants,
CREDIT BUREAU
CONNECTION, INC., a California
Corporation

STONE | ROSENBLATT | CHA

A PROFESSIONAL LAW CORPORATION
21550 OXNARD STREET, MAIN PLAZA – SUITE 200
WOODLAND HILLS, CALIFORNIA 91367

11
12

DATED: July 11, 2011
Law Offices of David A. Makman

13
14

By:

15
16
17
18
19

/s/
David A. Makman
Attorneys for Defendants and
Cross-claimants, WILLIAM
PARDINI and B.T.B. Inc. dba
DATA CONSULTANTS

IT IS SO ORDERED.

20
Dated:

21
22
23

/s/ Dennis

July 12, 2011

L. Beck

UNITED STATES MAGISTRATE JUDGE
DEAC _Signature- END:

3b142a

24
25
26
27
28
3
STIPULATION FOR SUBMISSION OF CLOSING DOCUMENTS AND [PROPOSED] ORDER
10cv1202.o.Stip Closing Doc